What happened?
TCC reported that the FCA has been actively emphasising the need for thorough evidencing of ongoing servicing under the Consumer Duty, even without high-profile public statements on the issue. In response, TCC hosted an exclusive in-person event on 16 September 2025 in London, bringing together wealth managers, legal experts and technology partners.
The event addressed the FCA’s expectations for substantive, evidenced annual reviews, documented client meetings and up-to-date fact finds and suitability letters, together with the ability to respond rapidly to section 165 information requests under the Financial Services and Markets Act 2000.
Speakers included representatives from Attivo, DACBeachcroft, TCC and Recordsure, sharing perspectives on data-led supervision strategies and the use of AI in ongoing advice reviews.
Why does it matter?
Firms without modern technology or significant manual resource may struggle to meet the FCA’s expectations for substantive, evidenced reviews. Inconsistent processes or weak records leave firms exposed to resource-heavy FCA investigations and more serious consequences if failings are identified.
Who is affected?
Wealth management firms providing ongoing advice services under the Consumer Duty, and the compliance and supervision teams responsible for responding to FCA information requests.
Recommendations
Firms should sharpen data-led supervision of ongoing advice now, rather than waiting for a formal FCA information request to expose gaps in evidencing and record-keeping.
Frequently asked questions
What does the FCA expect from ongoing advice reviews under the Consumer Duty?
Substantive, evidenced annual reviews, documented client meetings, up-to-date fact finds and suitability letters, and the ability to respond quickly to section 165 information requests.
When and where was TCC's event held?
On 16 September 2025 at The Bloomsbury in London.
Who spoke at the event?
Representatives from Attivo, DACBeachcroft, TCC and Recordsure.
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Reviewed by TCC Group Editorial Team
